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Latest news & developments

13 February 2019

Registration to the UBO register: extension of the deadline until 30 September

We already informed you about the introduction in Belgium of a register regarding the Ultimate Beneficial Owners (UBO’s) of legal entities. Initially, the information on the UBO’s needed to be registered by 30 November 2018. However, the deadline had been extended till 31 March 2019 by the Federal Public Service Finance (FPSF) taken into account

12 February 2019

Upcoming due date for electronic filing of BEPS 13 related documents: 28 February 2019

Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities. The deadlines, criteria and formalities should therefore be followed up closely. Please find below a short summary of the obligations to be complied with by 28 February 2019. What? Belgian entities – if they meet certain criteria – have to

5 February 2019

Belgian Net Asset Tax and Withholding Tax: opportunities to reclaim for Luxembourg SICAV

In a decision dated 29 November 2018, the Court of Appeal of Brussels concluded that the Double Tax Treaty concluded between Belgium and Luxembourg (hereinafter the ‘DTT’) prevents the application of the Belgian Net Asset Tax (hereinafter the ‘NAT’) to a Luxembourg SICAV. As it confirms that a Luxembourg SICAV falls within the personal scope

1 February 2019

2019 implementation of Belgian 30% EBITDA rule approved

On 31 January 2019, the Chamber approved the advancement of the implementation date of the new interest limitation rule (30% EBITDA rule). The law will become effective after it is signed by the King and published in the Official Gazette. Concretely, this means that the Belgian 30% EBITDA rule will enter into force retroactively as from

30 January 2019

Brexit Update – Mrs May sent back to Brussels Time to anticipate now!

Yesterday the House of Commons voted on the amendments which will shape the next steps of the Brexit. Members of the Parliament voted the amendment to scrap the most difficult part of the Withdrawal Agreement; being the Irish back stop and send Mrs May back to Brussels for further negotiations. In response to the vote,

29 January 2019

Negative ruling highlights pitfalls of pre-deal carve-outs through partial demergers

In a recent decision, the Belgian ruling office rejected a pre-deal carve-out of real estate through a tax neutral partial demerger followed by a tax exempt transfer of shares of the operating company. Though the ruling does not particularly divulge novel views, it has the merit of highlighting common pitfalls related to these type of